version 1.0: july 2019€¦ · frequently asked questions on the commission website. advisories,...

Fugitive Emissions

Management

Guideline VERSION 1.0: July 2019

Page: 2

BC Oil and Gas Commission V 1.0 published: July 2019

Uncontrolled copy once downloaded

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Fugitive Emissions Management Guideline

About the Commission

The BC Oil and Gas Commission (Commission) is the single-window regulatory agency

with responsibilities for regulating oil and gas activities in British Columbia, including

exploration, development, pipeline transportation and reclamation.

The Commission’s core roles include reviewing and assessing applications for industry

activity, consulting with First Nations, ensuring industry complies with provincial legislation

and cooperating with partner agencies. The public interest is protected by ensuring public safety,

protecting the environment, conserving petroleum resources and ensuring equitable participation in production.

VISION

Safe and responsible energy resource development for British Columbia.

MISSION

We provide British Columbia with regulatory excellence in responsible energy resource development by

protecting public safety, safeguarding the environment and respecting those individuals and communities who

are affected.

VALUES

Transparency

Is our commitment to be open and provide clear information on decisions,

operations and actions.

Innovation

Is our commitment to learn, adapt, act and grow.

Integrity

Is our commitment to the principles or fairness, trust and accountability

Respect

Is our commitment to listen, accept and value diverse perspectives.

Responsiveness

Is our commitment to listening and timely and meaningful action.

http://www.bcogc.ca/public-zone/fact-sheets

http://www.bcogc.ca/legislation

http://www.bcogc.ca/

Additional Guidance

As with all Commission documents, this manual does not take the place of applicable legislation. Readers are

encouraged to become familiar with the acts and regulations and seek direction from Commission staff for

clarification. Some activities may require additional requirements and approvals from other regulators or create

obligations under other statutes. It is the applicant and permit holder’s responsibility to know and uphold all legal

obligations and responsibilities.

Throughout the manual there are references to guides, forms, tables and definitions to assist in creating and

submitting all required information. Additional resources include:

Glossary and acronym listing on the Commission website.

Documentation and guidelines on the Commission website.

Frequently asked questions on the Commission website.

Advisories, bulletins, reports and directives on the Commission website.

Regulations and Acts listed on the Commission website


http://www.bcogc.ca/industry-zone/documentation

http://www.bcogc.ca/industry-zone/faq

http://www.bcogc.ca/publications


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Table of Contents

About the Commission ................................................................................................................................... 2

Additional Guidance....................................................................................................................................... 3

Manual Revisions .......................................................................................................................................... 5

Chapter 1: Preface......................................................................................................................................... 6

1.1 Scope ........................................................................................................................................................................... 6

1.2 How to Use This Guideline ......................................................................................................................................... 6

1.3 Acknowledgement ....................................................................................................................................................... 6

Chapter 2: Developing a Fugitive Emissions Management Plan ................................................................... 7

2.1 Accountability ............................................................................................................................................................... 7

2.2 Roles and Responsibilities .......................................................................................................................................... 7

2.3 Preventive Maintenance ............................................................................................................................................. 9

2.4 Continuous Improvement ........................................................................................................................................... 9

Chapter 3: Leak Detection Surveys ................................................................................................................... 11

3.1 Survey Frequency ..................................................................................................................................................... 11

3.1.1 Proration of Required Comprehensive Survey Frequency ................................................................ 13

3.1.2 Proration of Required Screening Survey Frequency ........................................................................ 14

3.1.3 General Comprehensive Survey Spacing Requirement ................................................................... 14

3.2 Survey Scope ............................................................................................................................................................ 15

3.3 Sources of Fugitive Emissions ................................................................................................................................. 17

3.4 Survey Procedures .................................................................................................................................................... 18

3.4.1 Comprehensive Surveys- Detection Methods ................................................................................. 18

3.4.2 Comprehensive Surveys- Measurement Methods ........................................................................... 21

3.4.3 Screening Surveys ...................................................................................................................... 23

3.4.4 Training and Competency ............................................................................................................ 24

Chapter 4: Repairs....................................................................................................................................... 26

Chapter 5: Data Management ..................................................................................................................... 28

Appendix A: Data Collection ........................................................................................................................ 30




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Manual Revisions

The Commission is committed to the continuous improvement of its documentation. Revisions to the

documentation are highlighted in this section and are posted to the Documentation Section of the Commission’s

website. Stakeholders are invited to provide input or feedback on Commission documentation to

[email protected] or submit feedback using the feedback form.

Version

Number

Posted

Date

Effective

Date

Chapter

Section

Summary of Revision(s)

1.0 July 18,

2019

January 1,

2020 Various

This is a new document. Users are

encouraged to review in full.

For more information, refer to INDB

2019-18 on the Commission’s

website.




http://www.bcogc.ca/industry-zone/documentation

mailto:[email protected]

http://www.bcogc.ca/industry-zone/bts/application-management-system

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Chapter 1: Preface

This Fugitive Emissions Management Guideline provides regulatory requirements and guidance for fugitive

emissions management in British Columbia. The guideline applies to fugitive emissions at wellsites and facilities

regulated under the Oil and Gas Activities Act (OGAA). It does not apply to liquefied natural gas (LNG) facilities.

1.1 Scope

This guideline focuses exclusively on requirements and processes associated with the BC Oil and Gas

Commission’s (Commission) legislative authorities and does not provide information on legal responsibilities

that the Commission does not regulate. It is the responsibility of the applicant or permit holder to know and

uphold its other legal responsibilities.

1.2 How to Use This Guideline

Commission requirements and recommended practices are included within each section and subsection

throughout the guideline. “Must” indicates a requirement for which compliance is expected and may be

subject to Commission enforcement, while “recommends” or “should” indicates a best practice that should

be used by the applicable party.

1.3 Acknowledgement

The Commission would like to acknowledge the Alberta Energy Regulator (AER) for their input into this

guideline through allowing the Commission to use material from Manual 16 throughout this guideline.

Contributions from industry, environmental non-governmental organizations, academia, service providers

and government are also gratefully acknowledged.




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Chapter 2: Developing a Fugitive Emissions Management

Plan

Fugitive Emissions Management Plans (FEMP) detail how a permit holder’s fugitive emissions will be systematically

detected, managed and reported.

Permit holders should develop a written FEMP. FEMPs and associated data should be reviewed annually and

continuous improvements to the plan should be made as appropriate.

2.1 Accountability

The FEMP should clearly identify which individual is accountable (operator representative) along with their

title and contact information. This individual should be a senior officer as defined in the Greenhouse Gas

Emission Reporting Regulation.

2.2 Roles and Responsibilities

The FEMP should document internal (e.g., individual staff, groups, departments) and external (e.g.,

contractors) resources allocated to develop, implement, maintain and update the FEMP, with their

specific responsibilities identified. Table 2.1 provides an example of how a permit holder might allocate and

document FEMP resources and responsibilities.




https://www2.gov.bc.ca/gov/content/environment/climate-change/planning-and-action/legislation#ggerr


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Table 2.1. Example of how resources might be allocated and documented in a FEMP

Resource Responsibility

Corporate management Maintain corporate commitment to the FEMP.

Approve annual FEMP budget.

Review and sign annual certification statement.

FEMP management team Develop and maintain FEMP review schedule.

Create comprehensive survey and screening survey schedule.

Oversee data management system.

Submit reports to the Commission.

Assess the FEMP’s effectiveness and opportunities for continuous

improvement.

Provide updates, develop annual reports, and make

recommendations.

Fugitive emissions surveyors Maintain and calibrate test equipment.

Perform comprehensive surveys.

Perform screening surveys.

Generate individual facility/wellsite reports.

Generate summary reports.

Identify components that require repair, replacement, or retrofit.

Determine leak severity, and measure or estimate emissions rate.

Maintain electronic system to capture and retain data.

Maintain monitoring schedules.

Confirm integrity of repairs.

Field operators Provide guidance on comprehensive survey and screening survey

schedules.

Supervise surveyors and provide them with information about

facility performance and operation during comprehensive surveys

and screening surveys.

Review facility /wellsite reports and develop work plans (work

orders) to address recommendations.

Maintenance team Repair leaks or modify facilities / wellsites (e.g., install test ports,

repipe vent lines).

Close out work orders and record repair details.




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2.3 Preventive Maintenance

A FEMP should indicate what preventive maintenance practices the permit holder is using to reduce or

prevent fugitive emissions. This might include checklists used by field operators during routine inspections,

regularly scheduled maintenance programs, and maintenance programs or standard operating procedures

that incorporate preventive maintenance practices.

The following preventive maintenance practices could be incorporated into operations and maintenance

practices to reduce fugitive emissions:

Tighten loose connections (especially in a vibrating service).

Plug or eliminate open-ended lines.

Inspect and confirm positive isolation capability of separator and scrubber dump valves.

Inspect and maintain pressurized pneumatic devices and pumps (e.g., controller case seals).

Fix or replace pressurized pneumatic devices and pumps that are not operating within

manufacturer written specifications.

Inspect and maintain thief hatches.

Inspect and maintain pressure relief valves (PRVs) and pressure vent relief valves (PVRVs).

Close thief hatches if found open on tanks with vent gas control.

Ensure combustion systems remain lit when facility or wellsite is pressurized and active.

Ensure control equipment (such as vapour recovery unit) is operational (except when it is down for

maintenance) and is operating and maintained as designed.

Look for and correct abnormal process events.

2.4 Continuous Improvement

The FEMP should describe how data will be used to evaluate performance and inform continuous improvement.

The following are indicators that could be used to evaluate the performance of a FEMP and to determine if any

changes are needed:

Quantified emissions reductions over time (e.g., by corporate or operating area, or by facility type or

equipment).

Cost of detection (e.g., $/kg methane detected).

Volume of gas conserved by managing fugitive emissions.

Number of leaking components over time (e.g., by corporate or operating area or by facility type or

equipment).

Specific components within facilities that are more prone to leaks.




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Time between leak detection and repair.

The FEMP should indicate methods used to review data, how often data are reviewed, and how changes will be

made to the FEMP following these reviews.




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Chapter 3: Leak Detection Surveys

This chapter provides technical guidance to permit holders on leak sources, detection and measurement technology

and methods, as well as leak detection survey timing and frequency.

3.1 Survey Frequency

The FEMP should have documented procedures and plans for meeting the required frequency of fugitive

emissions comprehensive surveys and screening surveys detailed in Tables 3.1 to 3.3 including tracking for:

Number of comprehensive surveys or screening surveys required and completed at each facility or

wellsite (Drilling and Production Regulation (DPR) Section 41.1 (2) (3)).

Results of comprehensive surveys and screening surveys and the status of all repairs (DPR

Section 41.1(7)).

Fugitive emissions comprehensive survey and screening survey requirements apply only to facilities and

wellsites with active (e.g. pressurized in part or in whole) equipment. Required comprehensive survey

frequencies vary according to facility type, control equipment present in the case of single well batteries

(controlled versus uncontrolled storage tanks of any size that store produced water, condensate, or oil), by

production type, and by the presence or absence of storage tanks. Minimum acceptable comprehensive

survey frequencies for regulatory compliance are detailed in Table 3.1.

Screening surveys must be done a minimum of annually at any facility not listed in Table 3.1 (DPR Section

41.1(2)) and at any conventional wellsite (wellsite producing from a zone not listed in Schedule 2 of the

DPR) that does not have a storage tank (DPR Section 41.1(3)).

The FEMP should indicate how companies track when comprehensive or screening surveys are required

and (DPR Section 41.1 (2)(3)(4)) the procedures used to ensure that all applicable components and natural

gas driven pressurized pneumatic devices are surveyed at each site (DPR Section 41.1(2)).

Survey frequencies do not change based on the hydrogen sulphide concentration within any stream at a

facility or wellsite.




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Table 3.1: Minimum Acceptable Comprehensive Survey Frequencies

Facility Type Description Number of Comprehensive

Surveys Required Per Year

Gas Processing Plant As defined in the Drilling and

Production Regulation

3

Compressor Station Any facility containing a type A or

type B compressor, as defined in

the Drilling and Production

Regulation

3

Multi-well Battery Battery as defined in the Drilling

and Production Regulation with link

to more than one well

3

Single-well Battery with Controlled

Storage Tank

Battery as defined in the Drilling

and Production Regulation with link

to one well

3

Custom Treating Facility As defined in the Oil and Gas

Glossary and Definitions

1

Injection/Disposal Facility Injection station or disposal station,

as defined in the Oil and Gas

Glossary and Definitions

1

Wellsites with Unconventional

Production

Unconventional production as

defined in Schedule 2 of the Drilling

and Production Regulation

1

Facility or Well with Storage Tank Example include: Gas Dehydrator,

Fractionation Facility, Pump

Station, and Tank Terminal, as

defined in the Oil and Gas Glossary

and Definitions

1

It is expected that all co-located wellsites and facilities undergo leak detection surveys whenever any of

them is surveyed. For example, if a wellsite is co-located with a multi-well battery, each time the multi-well

battery is surveyed, the co-located wellsite would also be surveyed.




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3.1.1 Proration of Required Comprehensive Survey

Frequency

The number of comprehensive surveys undertaken per calendar year at a facility may be adjusted as

indicated in Table 3.2. Minimum comprehensive survey spacing requirements are not affected by the

adjustments.

Table 3.2: Proration of Three Comprehensive Surveys per Year

Days Active (Pressurized) per

Calendar Year

Number of Comprehensive Surveys

Required per Calendar Year

0-30 0

31-121 1

122-243 2

244-365 3

The number of comprehensive surveys undertaken per calendar year at a facility or wellsite may be

adjusted as indicated in Table 3.3. Minimum comprehensive survey spacing requirements are not affected

by the adjustments.

Table 3.3: Proration of One Comprehensive Survey per Year

Days Active (Pressurized) Per

Calendar Year

Number of Comprehensive

Surveys Required Per Calendar

Year

0-90 0

91-365 1

If proration of comprehensive survey frequencies is used, records of well and/or facility operating hours must

be submitted to the Commission through eSubmission by no later than May 31 of the year after which the

proration was used.




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3.1.2 Proration of Required Screening Survey

Frequency

Proration of the number of screening surveys undertaken per year at facilities and wellsites is not

permissible.

3.1.3 General Comprehensive Survey Spacing

Requirement

At facilities where more than one comprehensive survey is required per calendar year each comprehensive

survey must be conducted at least 60 days from the last comprehensive survey conducted as per Section

41.1(4)(a) of the DPR. The spacing between surveys may cross calendar years. For example, a survey at a

gas plant could be conducted in December of one year and then again in March of the following year. At

facilities where one comprehensive survey is required per calendar year each comprehensive survey must

be conducted a minimum of 9 months apart from the last comprehensive survey conducted as per Section

41.1(4)(b) of the DPR. The spacing between surveys may cross calendar years.

Facility Turnarounds

Comprehensive surveys should be conducted within 14 days after the completion of a facility turnaround.

The end of the turnaround is determined by the resumption of operations (full or partial).

Comprehensive surveys conducted after a facility turnaround apply towards the number of comprehensive

surveys required at a facility each calendar year provided they also meet the general comprehensive survey

spacing requirement.

Post Construction

Comprehensive surveys and screening surveys should be conducted within 30 days after the completion of

construction activities. This includes the construction of new facilities (greenfield), as well as any

modifications of existing (brownfield) facilities.

Pre-commissioning inspections are considered by the Commission to be a suitable alternative to post

construction surveys.




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For facilities and wellsites, the start of the 30 day time period is the first day of startup.

Comprehensive surveys conducted after facility construction apply towards the number of comprehensive

surveys required at a facility each calendar year provided they also meet the general comprehensive survey

spacing requirement.

Inactive Wells and Facilities

Comprehensive surveys and screening surveys should be conducted within 14 days after the reactivation of

a facility or well. Reactivation is achieved the first day of production (wellsite) or receipts to a facility.

Comprehensive surveys and screening surveys conducted after the reactivation of a facility or well apply

towards the number of comprehensive surveys and screening surveys required at a facility or well each

calendar year provided they also meet the general comprehensive survey and screening survey spacing

requirements.

3.2 Survey Scope

Comprehensive surveys and screening surveys must include all equipment and components at a facility or

wellsite that could be a source of fugitive emissions, including pressurized pneumatic devices (Section

41.1(2) DPR) unless the components are unsafe to survey, difficult to survey or inaccessible to survey.

Unsafe, difficult or inaccessible components do not need to be included until it becomes feasible to do so.

Documentation stating why the component is unsafe, difficult or inaccessible to include in the survey must

be detailed in each survey report.

Difficult to survey components are those that cannot be surveyed without elevating the surveyor more than

two (2) metres above a supported surface or are unable to be reached via a wheeled scissor-lift or hydraulic

type scaffold that allows access to components up to 7.6 metres above the ground.

Unsafe to survey components are those that cannot be surveyed without exposing surveyor to an immediate

danger as a consequence of completing the survey. This is dependent on the survey method used.

Inaccessible to survey components are those that are buried, insulated, or obstructed by equipment or

piping that prevents access to the components by surveyor.

Survey technicians must use survey techniques that allow them to safely and effectively detect leaks at

storage tank components. When the survey method used includes optical gas imaging, if there is a

reasonable line of sight to a component, it must be surveyed.




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The permit holder must survey the following:

Pressurized equipment components with hydrocarbon throughput.

Natural gas–driven pressurized pneumatic devices.

Tank-top equipment, including thief hatches and gauge-board assemblies and pressure relief

devices.

Pressure relief valves.

Equipment used to combust vent gas, including burners, flare ignitors, pilots.

Combustors.

Equipment used to conserve vent gas, including vapour recovery units and vent gas capture

systems.

It is recommended that, should liquid loading/unloading activities take place while a comprehensive survey

using an optical gas imaging camera is being conducted, that the liquid loading/unloading activities be

included within the scope of the survey.

Leaks detected as part of comprehensive surveys must be quantified by measurement (DPR Section

41.1(7)). Where quantification by measurement is not possible for safety reasons, because the leak is

inaccessible, difficult to survey or because the leak is too small or large to measure, quantification must be

done by engineering estimate or emission factor (DPR Section 41.1(7)).

Leaks detected as part of screening surveys must be quantified by either measurement, engineering

estimate, or emission factor (DPR Section 41.1(7)).

Leak rates and corresponding quantification methods must be submitted to the Commission using

eSubmission.

When leak rates are quantified by engineering estimate or emission factor a methodology that is in

accordance with the Greenhouse Gas Emission Reporting Regulation must be used. The estimation of

leaks by empirical experience is not acceptable (DPR Section 41.1(7)).

A summary of leak quantification requirements is provided in Table 3.4.

Table 3.4: Leak Quantification Requirements

Type of Survey

Type of Leak

Outside Measurement Device Range

Inaccessible, Difficult to Survey or Unsafe to

Access Other

Comprehensive Emission Factor or Engineering Estimate Measure

Screening Emission Factor, Engineering Estimate, or Measure





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3.3 Sources of Fugitive Emissions

Standard Equipment Components

Fugitive emissions from standard equipment components are the result of components wearing out or

failing over time, being improperly installed, or loosening due to vibration. These fugitive emissions can

often be easily detected during a fugitive emissions comprehensive survey or screening survey, and the

component can often be immediately refitted, repaired, or replaced.

The following components are common sources of fugitive emissions:

Connections (especially threaded connections) and fittings.

Instruments and valves (e.g., pressure relief valves and control valves).

Seals and housings (e.g., pressurized pneumatic controller case seals and tank thief hatch seals).

Abnormal Processes

Fugitive emissions from abnormal processes typically result from equipment malfunctioning or becoming

inoperative, or from processes functioning abnormally. These types of emissions may be more difficult to

detect because they can be more intermittent and may require a detailed investigation before the source

can be identified and repaired.

The following abnormal processes are common sources of fugitive emissions:

Unlit flares (ignitors and pilots).

Malfunctioning pressurized pneumatic devices.

Conservation units (e.g., vapour recovery units) that have quit operating.

Equipment components emitting vent gas upstream of equipment actively controlling vent gas.

Hydrocarbon storage tanks can also be sources of fugitive emissions from abnormal processes when:

Thief hatches are open outside the time required for pressure relief.

Leaking process gas or volatile product moves past the seats of drains or blowdown valves.

Gas and liquids are separated inefficiently allowing gas to carry through.

Production changes result in high vapour carry through.

Pigging operations displace large volumes of gas to the tank.




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3.4 Survey Procedures

A FEMP should describe the methods and equipment used for comprehensive surveys and screening

surveys including the make and model of the equipment used. It is not necessary to use the same type of

equipment for all comprehensive surveys and screening surveys (DPR Section 41.1 (1)).

3.4.1 Comprehensive Surveys- Detection Methods

The two leak detection survey technologies that, when they meet the minimum specifications in this

guideline and when used in accordance with the procedures in the guideline, are accepted as

comprehensive survey methods under the Drilling and Production Regulation are organic vapour analyzers

(US EPA Method 211) and optical gas imaging (OGI) cameras.

OGI cameras must be capable under laboratory conditions of detecting 1 gram per hour of pure methane

emitted at:

A distance of 3 metres between the camera and the emission.

A difference between air temperature and background temperature of no greater than 10 degrees

Celsius.

Before using any survey equipment, the surveyor must make sure that it can be safely operated in the

area and take any necessary precautions. Before starting the survey, the surveyor should identify a

scanning path to ensure all areas of the facility are surveyed. It is usually best to follow the path of the

product from inlet to outlet. The surveyor might also conduct the survey by individual process units and then

check off each unit as it is surveyed.

Meteorological conditions, such as rain and wind, can make it more difficult to detect fugitive emissions.

For example, higher winds can distribute plumes more quickly, making them harder to detect.

Comprehensive surveys conducted during meteorological conditions that substantially compromise their

effectiveness should be avoided, were practicable (surveys done at wind speeds greater than 4 m/s, during

moderate to heavy precipitation events, at ambient temperatures below -20 degrees Celsius).

1 EPA Method 21 means the method of the Environmental Protection Agency of the United States entitled Method 21 — Determination of Volatile Organic Compound Leaks, set out in Appendix A-7 to Part 60 of Title 40, chapter I of the Code of Federal Regulations of the United States.




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Leaks detected as part of comprehensive surveys must be quantified as described in Table 3.4 (DPR

Section 41.1(7)).

Organic Vapour Analyzer

Organic vapour analyzers, sometimes called toxic vapour analyzers, are portable analyzers typically

equipped with photoionization detectors (PIDs) or flame ionization devices (FIDs). Other types of sensors

include catalytic oxidation or infrared absorption sensors.

When completing surveys using an organic vapour analyzer:

Manufacturer written recommendations for the specific type of equipment used must be followed

(DPR Section 41.1(1) (a)).

The tip of the analyzer’s probe must be traced along the leak interface as close as possible to the

component’s surface.

Surveyors must ensure that the analyzer reaches its full metre reading by keeping the analyzer’s

probe in place until the reading levels out or peaks.

To prevent falls when surveying elevated components, surveyors may use an extension probe on

the analyzer rather than a ladder.

When multiple components are close together, it can be difficult to identify the location of a leak.

Surveyors must take the time to ensure that the correct source is identified and may use soap

testing to help confirm the leak location.

Surveys must be conducted at a pace that is appropriate for the size of the component and its

configuration. Larger components will take more time to survey if a uniform probe speed is used.

As a general rule, a speed of 3 cm per second should be used, moving more slowly when

inspecting areas with higher potential for leaks.

Gas Imaging Cameras

Gas imaging cameras, often referred to as optical gas imaging cameras, are a tool for detecting

fugitive emission sources. These cameras provide images and video recordings of leaks that are invisible to

the human eye. In addition, they can be used when it is not practical to use an organic vapour analyzer

(e.g., when the component is hard to reach or is difficult to access with the analyzer’s probe) and can be

used to detect fugitive emissions from a distance.

The ability of an OGI camera to detect fugitive emissions depends on several factors, such as distance

from source, atmospheric conditions, thermal gradient, and surveyor competency.

When completing comprehensive surveys using an OGI camera:




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Manufacturer written recommendations for the specific type of equipment used must be followed.

(DPR Section 41.1(1) (a)).

Surveyors should stand 1.5 to 3 metres from the equipment being surveyed (for detection

purposes), depending on the size and accessibility of the equipment. (For quantification by

quantitative OGI, standing further back may be sometimes be appropriate.)

Surveyors should divide the field of view in the camera view finder into quadrants and scan each

quadrant to look for gas movement from each component. Gas movement might be visible only

when the gas moves from the component to the background. If contrast is low or movement is

difficult to observe, the high-sensitivity mode of the camera might help with detection.

Each piece or group of equipment should be scanned from a wide angle in order to identify any

apparent emissions. After a wide-angle scan, detailed scans should be done to identify the specific

fugitive emissions source and to detect any lower-rate fugitive emissions not visible in the wide-

angle scan. Each piece of equipment should also be scanned from at least two separate

viewpoints to increase the probability of emissions detection.

If the temperature of the leaking gas is similar to the surrounding area, surveyors should adjust the

temperature span on the camera to compensate for low thermal contrast to improve their ability to

identify a leak (e.g., when the component being surveyed is close to a heater or boiler) (DPR

Section 41.1(1) (b)).

Surveyors must consider, to the extent practicable, whether there are any factors such as ambient

weather conditions or surrounding physical structures that could affect the ability to detect the

fugitive emissions and take these into account when conducting a survey. Surveys should not be

conducted during weather conditions that undermine quality when it can be avoided (moderate and

heavy precipitation, wind speeds> 4m/s, ambient temperatures below -20 degrees Celsius).

It is difficult to see gas movement when the camera is in motion, so the camera is to be held still on

one scene for a few seconds before moving on to the next. This is so that video can be used for

quantitative OGI by the surveyors or by others after the survey is complete.

It can be challenging to distinguish between hydrocarbon gas and other hot gases, such as steam.

When viewed through a camera, steam will dissipate quickly as it cools, but a hydrocarbon gas

plume often remains visible for longer.

When comprehensive surveys using optical gas imaging cameras are conducted at very cold temperatures

(below approximately -20 Celsius) physical limitations with the camera may be experienced such as LCD

screen freezing or a high battery discharge rate. Efforts to keep the camera warm such as minimizing the

time spent outside and the use of heating pads and/or blankets may be used. (DPR section 41.1(1) (b)).

Acoustic Leak Detection

Leakage from level control valves on separators and scrubbers to tankage without operating vapour

recovery or thermal control devices must be monitored as part of comprehensive surveys by using an

acoustic leak detection device as per the Greenhouse Gas Emission Reporting Regulation. Any leakage

found must be reported as a leak (DPR Section 41.1(7)).




http://www.bclaws.ca/civix/document/id/loo99/loo99/249_2015

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When completing comprehensive surveys using an acoustic leak detection device follow manufacturer

written recommendations for the specific device used.

3.4.2 Comprehensive Surveys- Measurement

Methods

Commission approved leak measurement devices for comprehensive surveys are as follows:

1. Quantitative optical gas imaging.

2. High flow sampler.

3. Full flow meter.

4. Calibrated bag.

5. Other measurement devices, approved in consultation with the Commission.

Quantitative Optical Gas Imaging Camera

Quantitative Optical Gas Imaging (QOGI) is a technology that is designed to work with an optical gas

imaging camera as an add-on module. The module uses image information (pixel intensity and number of

pixels) and supplementary data (distance from camera to the plume and ambient air temperature) to

calculate the mass rate of the release. Leak video should be collected for a minimum of 120 seconds for

audit purposes (DPR Section 41.1(7)).

When measuring emissions using an optical gas imaging camera follow manufacturer written specifications

for the specific device used.

When QOGI is being used for measurement purposes, a tripod should be used to steady the camera (DPR

Section 41.1 (7)).

It is expected that leaks between 0.018 m3/hr and 18 m3/hr can be measured using QOGI2.

High Flow Sampler

A high flow sampler includes a sampling hose, an instrumentation box containing a blower and combustibles

sensors, a battery pack, and a control pad/display. The high flow sampler draws a sample of the air around

2 FAQ: Providence Photonics QL320 and QOGI




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a leak and measures pressure differential across an orifice restrictor as well as methane concentration using

sensors. This information is used to calculate the leak flowrate.

It is expected that leaks between 0.085 m3/hr and 13.6 m3/hr can be measured using a high flow sampler3.

When measuring emissions using a high flow sampler follow manufacturer written recommendations for the

specific device used with the following exceptions:

High flow sampler is recommended to be calibrated daily (must be calibrated monthly).

Firmware version 3.03 or greater must be used4.

If the high flow sampler is not calibrated daily or Firmware version 3.03 or greater is not used, an additional

method of measurement should be undertaken in addition to the use of the high flow sampler (DPR 41.1

Section (7)).

Full Flow Meter

Leak flow rate can be measured with a variety of instruments such as a diaphragm flow meter, rotary meter,

orifice meters and ultrasonic flow meter.

When measuring emissions using a full flow meter written manufacturer specifications are to be followed.

Calibrated Bag

A calibrated bag is a bag for measuring the flow rate from a vent or open line. The bag

has a known volume and a neck sized to fit over openings. The leak rate is determined as

the volume of the calibrated bag divided by the fill time.

It is expected that leaks up to 408 m3/hr can be measured using a calibrated bag.5

When measuring emissions using a calibrated bag follow written manufacturer recommendations for the

specific bag used.

3 Section 8.5.2.3 Update of Equipment, Component and Fugitive Emission Factors for Alberta Upstream Oil and Gas, Alberta Energy Regulator, June 10, 2018 4 Howard, T., T. W. Ferrara, and A. Townsend-Small. 2015. Sensor transition failure in the high flow sampler: Implications for methane emission inventories of natural gas infrastructure. J. Air Waste Manag. Assoc. 65:856–862. doi:10.1080/10962247.2015.1025925 5 Section 8.5.2.1 Update of Equipment, Component and Fugitive Emission Factors for Alberta Upstream Oil and Gas, Alberta Energy Regulator, June 10, 2018




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Equipment Calibration and Maintenance

The FEMP should describe the methods of calibrating and practices for maintaining the survey equipment.

This should include how frequently any maintenance or calibration activities are conducted and any

procedures or tracking systems used to ensure that these activities are carried out (DPR Section 41.1(1)).

Documentation to demonstrate that equipment is being maintained and calibrated to the manufacturer’s

written specifications must be maintained.

3.4.3 Screening Surveys

The two screening survey methods that are currently approved for use by the Commission are the use of a

soap solution (bubble test) and using the senses of hearing, sight, and small (also known as Audio, Visual,

Olfactory (AVO)). Comprehensive survey methods approved by the Commission may also be used in place

of screening survey methods.

Leaks detected as part of screening surveys must be quantified as specified in Table 3.4 (DPR Section

41.1(7)).

Leak rates and the quantification methods must be submitted to the Commission using eSubmission.

Meteorological conditions, such as rain and wind, can make it more difficult to detect fugitive emissions.

Screening surveys conducted during under meteorological conditions that substantially compromise their

effectiveness (moderate or heavy precipitation, wind speeds greater than 4 m/s, ambient temperature below

-20 degrees Celsius) should be avoided, when practicable.

AVO Inspections

When carrying out AVO inspections, check for the following:

Stains, wet areas, or dripping around thief hatches, pressure vacuum relief valves, and gauge

board assemblies on storage tanks.

Frosting or sweating of valves and pressure-relief devices connected to vent lines.

Visible vapour or steam plumes from components.

Normally closed valves connected to vents or open-ended lines that are not fully closed or plugged.

Components that have been temporarily removed for inspection, maintenance, or other purposes

and have not been put back in place.

Unlit pilots and flares.




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Odours inside buildings and downwind of piping, process equipment, and storage tanks.

Sounds indicative of a leak.

Responses on hydrocarbon detection monitors (personal monitors).

Permit holders should make screening surveys part of their routine site visits.

Soap Testing

Soap or bubble testing can be an effective method to detect smaller leaks. A sprayer or squeeze bottle is

used to apply a soapy solution to an area where a leak is suspected. If a leak is present, bubbling occurs at

the location of a leak. Soap tests may not be effective in detecting leaks from equipment that is inaccessible,

has continuously moving parts, or has a surface temperature greater than the boiling point or less than the

freezing point of the soap solution.

3.4.4 Training and Competency

The FEMP should describe any internal and external surveyor training programs, including the topics

covered and the duration of training, and relevant certifications. The FEMP must also describe the specific

training for the types of equipment being used. The FEMP should also indicate how frequently the surveyors

will be trained and how often they will be retrained or recertified (DPR Section 41.1(1)).

Training of individuals conducting fugitive emissions comprehensive surveys and screening surveys should

include, at a minimum, the following:

Principles of detecting emissions with the equipment or method.

Operation and calibration of equipment.

Sources of fugitive emissions.

Factors that affect estimates of fugitive emissions (e.g., weather, temperature) and how to account

for them.

Interpretation of results.

Surveyors must also have experience detecting, measuring, recording, and reporting fugitive emissions. If

they do not, such as in the case of a person that is being trained, the trainee must work under the direct

supervision of a trained and experienced individual (DPR Section 41.1(1)).




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Surveyors must have adequate training and experience with design and operation of pneumatic devices so

that any natural gas driven malfunctioning (leaking) pneumatic devices and pumps will be detected during

both comprehensive and screening surveys.

Additionally, it is expected that all surveyors will have applicable site safety training and certificates.




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Chapter 4: Repairs

Permit holders must have procedures to track, manage, and verify the status of repairs and repair information must

be submitted to the Commission through eSubmission (DPR Section 41.1(7)).

The FEMP should describe the data management practices and systems used to ensure that comprehensive survey

and screening survey results trigger required repairs and that the repairs are captured for reporting purposes. System

details might include the names of software programs or applications used and the type of data managed by each

system. When multiple systems are used, the FEMP should explain how data flows between systems (e.g., how data

from surveys performed by third parties are integrated into the permit holder’s internal systems to track repairs).

The first attempt to repair a leak should be made quickly after discovery, unless parts are unavailable, the equipment

requires shutdown to complete repair, or other good cause exists.

Repairs can either be completed on site during or after comprehensive surveys or screening surveys. It is

recommended that maintenance or operations staff who can perform repairs accompany surveyors to complete

repairs that can be done immediately.

If parts are unavailable, they should be ordered promptly and the repair must be made within 30 working days of

receipt of the parts (DPR Section 41.1 (5)(6)). If successful repairs cannot be completed within 30 days due to the

need to order parts an exemption request to DPR Section 41.1(5)(a) must6 be made to the Commission to avoid

noncompliance. Requests must be in writing to [email protected].

Some leaks might require a shutdown to repair them, such as leaks from components that cannot be isolated and

leaks requiring the site to be depressured. If the facility must be depressured to complete the repair, the repair may

be deferred until the next facility turnaround provided that it does not create an offsite odour or safety hazard (DPR

Section 41(1)(a)(b)) or as directed by the Commission (DPR Section 41.1(5)).

All leaks at wellsites must be repaired within 30 days regardless of the need to depressure the wellsite (DPR Section

41.1(6)).

The integrity of all repairs made must be verified using either a soap solution or an instrument based method such as

optical gas imaging (DPR Section 41.1 (5)(6)) for the repairs to be considered to be successful.

6 This statement is must because the DPR does not allow for repair times to extend beyond 30 days.




mailto:[email protected]

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A repairable leak includes:

Any unintentional natural gas emission detected by an organic vapour analyzer with a concentration equal

to or greater than 500 parts per million.

Any unintentional natural gas emission detected by a gas imaging camera.

Information on each leak detected and repair made must be submitted to the Commission using the Commission’s

eSubmission portal (DPR Section 41.1 (7)).

Tagging

Physical tagging (tag is affixed to a leaking component that cannot be immediately repaired), is the most common

method of tagging. These tags should be hung either directly on the leaking component or in a position where it is

easy to determine the location of the leaking component. Tags should be uniquely numbered, weather resistant,

designed for high visibility, and securely hung using plastic zip ties or corrosion-resistant wire.

Alternative methods of tagging, such as geospatial identifiers, should identify fugitive emission sources

and provide sufficient information to enable repair. This information must include the date the leak was detected

(DPR Section 41.1 (7)).

Consideration should be given to leaving tags in place after repairs are made to monitor for recurrent leaks.




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Chapter 5: Data Management

Data management systems allow permit holders to track, manage, and analyze fugitive emissions data. These

systems should:

Track completed comprehensive, and screening surveys and repairs (including work orders).

Track scheduled comprehensive, and screening surveys and upcoming repairs (including tagging).

Track facility /wellsite and component performance data over time.

Enable data analysis to identify trends.

Generate data summaries for use in regulatory reports.

Record Keeping

Detailed records of all surveys conducted, leaks detected, and repairs made are required to be reported to the

Commission. Appendix A identifies the information that permit holders are required to either keep a record of for audit

purposes or submit to the Commission through eSubmission.

The keeping of and submission of records to the Commission, as detailed in Appendix A, is as follows:

Comprehensive surveys – required.

Screening surveys at facilities and wellsites

o Mandatory Screening Surveys: Those surveys conducted to meet the minimum

requirements of DPR Section 41.1(2) (3) – Records must be submitted to the Commission

through eSubmission.

o Voluntary Screening Surveys: Those surveys conducted in addition to those needed to meet

the minimum requirements of DPR Section 41.1(3) (b) - keep a record. Voluntary submission

can be made to the Commission through eSubmission.

An example of a mandatory screening survey is an annual screening survey at a wellsite with conventional

production (not listed in Schedule 2 of the DPR) that does not have a storage tank. If the conventional wellsite has a

storage tank, it would be subject to a minimum of one comprehensive survey per year (DPR Section 41.1(3) (a) (i))

and any screening surveys conducted at the wellsite would be considered to be voluntary.

An example of a voluntary screening survey is a daily screening survey at a compressor station. This is because

compressor stations are subject to mandatory comprehensive surveys under Section 41.1(2) (a) (ii) of the DPR.




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Data for each comprehensive survey and mandatory screening survey conducted must be submitted electronically to

the Commission through eSubmission by May 31 of each year for each survey conducted during the previous

calendar year. If May 31 occurs on a Saturday or a Sunday, the data are due on the following Monday (DPR Section

41.1 (7)). The first report is due by May 31, 2021.

Data for each leak found and for repairs must be submitted electronically to the Commission through eSubmission by

May 31 of each year for each survey conducted during the previous calendar year. If May 31 occurs on a Saturday or

a Sunday, the data are due on the following Monday (DPR Section 41.1 (7)). The first report is due by May 31, 2021.

Records related to leak detection, quantification, and repair must be retained for a period of not less than 7 years

after the date the leak detection, quantification, or repair was complete to meet the requirements of the Greenhouse

Gas Emission Reporting Regulation.

Data must be certified by a permit holder representative. This individual should be a senior officer as defined in the

Greenhouse Gas Emission Reporting Regulation.







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Appendix A: Data Collection

eSubmission

The following information is to be submitted to the Commission using eSubmission on an annual basis:

Facility/Well Data:

Commission facility / wellsite identifier.

Information on whether natural gas emitting pressurized pneumatic devices are present.

Information on whether storage tanks are present and whether or not they are controlled.

Reporting year.

Number of days facility or well was pressurized or partially pressurized.

Measurement Device Data (comprehensive surveys only):

Make.

Model.

Technician Data:

Name.

Leak Survey Data:

Date.

Ambient temperature (comprehensive surveys only).

Barometric pressure (comprehensive surveys only).

Wind speed (comprehensive surveys only).

Precipitation (comprehensive surveys only).

Information regarding whether the survey was conducted internally or by third parties.

Survey method.

Detection instrument make.

Detection instrument model.

Information regarding whether a leak or leaks were detected.




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Leak Data:

Information on whether or not the leak contains hydrogen sulphide.

Information on whether or not the leak is located within a building.

Process block in which the leak is located.

Leaking component type.

Leaking component service type.

Distance detection camera is located from leak (if applicable).

Distance quantification camera is located from leak (if applicable).

Leak rate.

Leak methane content.

Leak rate quantification method (if applicable).

Reason for non-measurement of leak (if applicable).

Repair Data:

Date of repair.

Information on whether the leak was repaired on the same day it was detected.

Leak repair confirmation method.

Leak repair method applied.

Basis of delay of leak (if repaired after 30 days of detection).

Information on whether the leak is scheduled to be repaired at the next turnaround (if applicable).

Anticipated date of next turnaround (if applicable).

Keep a Record

The following information is to be submitted to the Commission upon request:

Measurement Device Data:

Software version (if applicable).

Calibration date.

Maximum margin of error.

Calibration report.




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Technician Data:

Information on whether or not the technician’s employer is the site permit holder.

Employer name.

Employer business address.

Training entity name.

Training entity address.

Name of trainer.

Job title of trainer.

Training date(s).

Number of hours of training received.

Description of training received.

Leak Survey Data:

Survey report.

Leak Data:

Photograph of leak (comprehensive surveys only).

Video of leak (if applicable).

Repair Data:

Documentation verifying repair of leak.




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